Trelleborg Sealing Solutions US, Inc. v. TE Connectivity Corporation et al, No. 8:2020cv01966 - Document 30 (C.D. Cal. 2021)

Court Description: ORDER GRANTING STIPULATED PROTECTIVE ORDER 29 by Magistrate Judge Autumn D. Spaeth. (see document for details) (hr)

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Trelleborg Sealing Solutions US, Inc. v. TE Connectivity Corporation et al Doc. 30 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 TRELLEBORG SEALING 12 SOLUTIONS US, INC. 13 Case No. 8:20-cv-01966 JLS (ADSx) Magistrate Judge: Hon. Autumn D. Spaeth 14 Plaintiff, 15 v. 16 17 PRECISION WIRE COMPONENTS, 18 LLC D/B/A CREGANNA MEDICAL and DOES 1 through 10, inclusive, 19 ORDER GRANTING STIPULATED PROTECTIVE ORDER 20 Defendant. 21 22 23 This Stipulated Protective Order is between Plaintiff Trelleborg Sealing 24 Solutions US, Inc. (“TSS”) and Defendant Precision Wire Components LLC 25 D/B/A Creganna Medical (“Creganna”), by and through their respective counsel 26 of record: 27 28 1 STIPULATED PROTECTIVE ORDER Dockets.Justia.com 1 I. PURPOSES AND LIMITATIONS 2 Discovery in this action is likely to involve production of confidential, 3 proprietary, or private information for which special protection from public 4 disclosure and from use for any purpose other than prosecuting this litigation may 5 be warranted. Accordingly, the parties hereby stipulate to and petition the Court 6 to enter the following Stipulated Protective Order. The parties acknowledge that 7 this Order does not confer blanket protections on all disclosures or responses to 8 discovery and that the protection it affords from public disclosure and use extends 9 only to the limited information or items that are entitled to confidential treatment 10 under the applicable legal principles. The parties further acknowledge, as set forth 11 in Section XIII(C), below, that this Stipulated Protective Order does not entitle 12 them to file confidential information under seal; Civil Local Rule 79-5 sets forth 13 the procedures that must be followed and the standards that will be applied when a 14 party seeks permission from the Court to file material under seal. 15 16 II. GOOD CAUSE STATEMENT 17 This action is likely to involve trade secrets, customer and pricing lists 18 and other valuable research, development, commercial, financial, technical 19 and/or proprietary information for which special protection from public 20 disclosure and from use for any purpose other than prosecution of this action is 21 warranted. Such confidential and proprietary materials and information consist 22 of, among other things, confidential business or financial information, 23 information regarding confidential business practices, or other confidential 24 research, development, or commercial information (including information 25 implicating privacy rights of third parties), information otherwise generally 26 unavailable to the public, or which may be privileged or otherwise protected 27 28 2 STIPULATED PROTECTIVE ORDER 1 from disclosure under state or federal statutes, court rules, case decisions, or 2 common law. Accordingly, to expedite the flow of information, to facilitate the 3 prompt resolution of disputes over confidentiality of discovery materials, to 4 adequately protect information the parties are entitled to keep confidential, to 5 ensure that the parties are permitted reasonable necessary uses of such material 6 in preparation for and in the conduct of trial, to address their handling at the end 7 of the litigation, and serve the ends of justice, a protective order for such 8 information is justified in this matter. It is the intent of the parties that 9 information will not be designated as confidential for tactical reasons and that 10 nothing be so designated without a good faith belief that it has been maintained 11 in a confidential, non-public manner, and there is good cause why it should not 12 be part of the public record of this case. 13 14 III. DEFINITIONS 15 A. 16 Action: This pending federal law suit, Case No. 8:20-cv-01966 JLS (ADSx). 17 B. 18 designation of information or items under this Order. 19 C. 20 of how it is generated, stored or maintained) or tangible things that qualify 21 for protection under Federal Rule of Civil Procedure 26(c), and as specified 22 above in the Good Cause Statement. 23 D. 24 their support staff). Challenging Party: A Party or Non-Party that challenges the “CONFIDENTIAL” Information or Items: Information (regardless Counsel: Outside Counsel of Record and House Counsel (as well as 25 26 27 28 3 STIPULATED PROTECTIVE ORDER 1 E. Designating Party: A Party or Non-Party that designates information 2 or items that it produces in disclosures or in responses to discovery as 3 “CONFIDENTIAL.” 4 F. 5 regardless of the medium or manner in which it is generated, stored, or 6 maintained (including, among other things, testimony, transcripts, and 7 tangible things), that are produced or generated in disclosures or responses 8 to discovery in this matter. 9 G. Disclosure or Discovery Material: All items or information, Expert: A person with specialized knowledge or experience in a 10 matter pertinent to the litigation who has been retained by a Party or its 11 counsel to serve as an expert witness or as a consultant in this Action. 12 H. 13 Action. House Counsel does not include Outside Counsel of Record or any 14 other outside counsel. 15 I. 16 or other legal entity not named as a Party to this action. 17 J. 18 party to this Action but are retained to represent or advise a party to this 19 Action and have appeared in this Action on behalf of that party or are 20 affiliated with a law firm which has appeared on behalf of that party, and 21 includes support staff. 22 K. 23 directors, employees, consultants, retained experts, and Outside Counsel of 24 Record (and their support staffs). 25 L. 26 Discovery Material in this Action. 27 28 House Counsel: Attorneys who are employees of a party to this Non-Party: Any natural person, partnership, corporation, association, Outside Counsel of Record: Attorneys who are not employees of a Party: Any party to this Action, including all of its officers, Producing Party: A Party or Non-Party that produces Disclosure or 4 STIPULATED PROTECTIVE ORDER 1 M. Professional Vendors: Persons or entities that provide litigation 2 support services (e.g., photocopying, videotaping, translating, preparing 3 exhibits or demonstrations, and organizing, storing, or retrieving data in any 4 form or medium) and their employees and subcontractors. 5 N. 6 designated as “CONFIDENTIAL.” 7 O. 8 Material from a Producing Party. Protected Material: Any Disclosure or Discovery Material that is Receiving Party: A Party that receives Disclosure or Discovery 9 10 IV. SCOPE 11 A. 12 only Protected Material (as defined above), but also (1) any information 13 copied or extracted from Protected Material; (2) all copies, excerpts, 14 summaries, or compilations of Protected Material; and (3) any testimony, 15 conversations, or presentations by Parties or their Counsel that might reveal 16 Protected Material. 17 B. 18 of the trial judge. This Order does not govern the use of Protected Material 19 at trial. The protections conferred by this Stipulation and Order cover not Any use of Protected Material at trial shall be governed by the orders 20 21 V. DURATION 22 Even after final disposition of this litigation, the confidentiality obligations 23 imposed by this Order shall remain in effect until a Designating Party agrees 24 otherwise in writing or a court order otherwise directs. Final disposition shall be 25 deemed to be the later of (1) dismissal of all claims and defenses in this Action, 26 with or without prejudice; and (2) final judgment herein after the completion and 27 28 5 STIPULATED PROTECTIVE ORDER 1 exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action, 2 including the time limits for filing any motions or applications for extension of 3 time pursuant to applicable law. 4 5 VI. DESIGNATING PROTECTED MATERIAL 6 A. Exercise of Restraint and Care in Designating Material for Protection 7 1. Each Party or Non-Party that designates information or items 8 for protection under this Order must take care to limit any such 9 designation to specific material that qualifies under the appropriate 10 standards. The Designating Party must designate for protection only 11 those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, 13 documents, items, or communications for which protection is not 14 warranted are not swept unjustifiably within the ambit of this Order. 15 2. 16 Designations that are shown to be clearly unjustified or that have 17 been made for an improper purpose (e.g., to unnecessarily encumber 18 the case development process or to impose unnecessary expenses and 19 burdens on other parties) may expose the Designating Party to 20 sanctions. 21 3. 22 or items that it designated for protection do not qualify for protection, 23 that Designating Party must promptly notify all other Parties that it is 24 withdrawing the inapplicable designation. 25 B. Mass, indiscriminate, or routinized designations are prohibited. If it comes to a Designating Party’s attention that information Manner and Timing of Designations 26 27 28 6 STIPULATED PROTECTIVE ORDER 1 1. Except as otherwise provided in this Order (see, e.g., Section 2 B(2)(b) below), or as otherwise stipulated or ordered, Disclosure or 3 Discovery Material that qualifies for protection under this Order must 4 be clearly so designated before the material is disclosed or produced. 5 2. 6 following: Designation in conformity with this Order requires the 7 a. For information in documentary form (e.g., paper or 8 electronic documents, but excluding transcripts of depositions 9 or other pretrial or trial proceedings), that the Producing Party 10 affix at a minimum, the legend “CONFIDENTIAL” 11 (hereinafter “CONFIDENTIAL legend”), to each page that 12 contains protected material. 13 b. 14 available for inspection need not designate them for protection 15 until after the inspecting Party has indicated which documents 16 it would like copied and produced. During the inspection and 17 before the designation, all of the material made available for 18 inspection shall be deemed “CONFIDENTIAL.” After the 19 inspecting Party has identified the documents it wants copied 20 and produced, the Producing Party must determine which 21 documents, or portions thereof, qualify for protection under 22 this Order. Then, before producing the specified documents, 23 the Producing Party must affix the “CONFIDENTIAL legend” 24 to each page that contains Protected Material. A Party or Non-Party that makes original documents 25 c. 26 will or might reasonably include disclosure of Confidential 27 28 Depositions. Any deposition which a party determines 7 STIPULATED PROTECTIVE ORDER 1 Information shall be attended only by those persons entitled 2 to receive such Confidential Information pursuant to this 3 Stipulated Protective Order, but this shall not be construed to 4 allow any such person to attend a deposition he or she 5 otherwise would not be allowed to attend. During a 6 deposition, any party may ask the reporter to designate 7 certain portions of the testimony as confidential, in which 8 case the confidential portions shall be separately transcribed 9 and labeled as confidential. In addition, within thirty (30) 10 days after a copy of the transcript taken at the deposition is 11 delivered to the parties, counsel may designate the entirety or 12 any specified portion of the transcript or exhibits thereto as 13 Confidential by letter to the opposing party. Until such 14 thirty-day period expires, the entirety of such transcripts and 15 all exhibits thereto shall be treated as Confidential and 16 subject to this Agreement. After such thirty-day period 17 expires, such transcripts, exhibits or portions thereof 18 designated as Confidential shall be treated as such under this 19 Agreement. If no such designation is made within thirty 20 days, such transcripts or exhibits shall not be subject to this 21 Agreement, except as later agreed by the parties. 22 d. 23 and for any other tangible items, that the Producing Party affix 24 in a prominent place on the exterior of the container or 25 containers in which the information is stored the legend 26 “CONFIDENTIAL.” 27 28 For information produced in form other than document 8 STIPULATED PROTECTIVE ORDER 1 C. 2 The inadvertent, unintentional, or in camera disclosure of Confidential 3 Information shall not be deemed a waiver, in whole or in part, of any 4 party’s claim of confidentiality. Within fifteen (15) days of discovering 5 such inadvertent or unintentional disclosure, any party to this Agreement 6 must advise the other parties that the Confidential Information is to be 7 designated as Confidential under the terms of this Agreement. Upon timely 8 correction of inadvertent disclosure, the Receiving Party must make 9 reasonable efforts to assure that the material is treated in accordance with 10 Inadvertent Failure to Designate the provisions of this order. 11 12 VII. CHALLENGING CONFIDENTIALITY DESIGNATIONS 13 A. Timing of Challenges 14 1. 15 confidentiality at any time that is consistent with the Court’s 16 Scheduling Order. 17 B. Any party or Non-Party may challenge a designation of Meet and Confer 18 1. The Challenging Party shall initiate the dispute resolution 19 process under Local Rule 37.1 et seq. 20 C. The burden of persuasion in any such challenge proceeding shall be 21 on the Designating Party. Frivolous challenges, and those made for an 22 improper purpose (e.g., to harass or impose unnecessary expenses and 23 burdens on other parties) may expose the Challenging Party to sanctions. 24 Unless the Designating Party has waived or withdrawn the confidentiality 25 designation, all parties shall continue to afford the material in question the 26 27 28 9 STIPULATED PROTECTIVE ORDER 1 level of protection to which it is entitled under the Producing Party’s 2 designation until the Court rules on the challenge. 3 4 VIII. ACCESS TO AND USE OF PROTECTED MATERIAL 5 A. Basic Principles 6 1. A Receiving Party may use Protected Material that is disclosed 7 or produced by another Party or by a Non-Party in connection with 8 this Action only for prosecuting, defending, or attempting to settle 9 this Action. Such Protected Material may be disclosed only to the 10 categories of persons and under the conditions described in this 11 Order. When the Action has been terminated, a Receiving Party must 12 comply with the provisions of Section XIV below. 13 2. 14 Receiving Party at a location and in a secure manner that ensures that 15 access is limited to the persons authorized under this Order. 16 B. Protected Material must be stored and maintained by a Disclosure of “CONFIDENTIAL” Information or Items 17 1. Unless otherwise ordered by the Court or permitted in writing 18 by the Designating Party, a Receiving Party may disclose any 19 information or item designated “CONFIDENTIAL” only to: 20 a. 21 Action, as well as employees of said Outside Counsel of 22 Record to whom it is reasonably necessary to disclose the 23 information for this Action; 24 b. 25 Counsel) of the Receiving Party to whom disclosure is 26 reasonably necessary for this Action; 27 28 The Receiving Party’s Outside Counsel of Record in this The officers, directors, and employees (including House 10 STIPULATED PROTECTIVE ORDER 1 c. Experts (as defined in this Order) of the Receiving Party 2 to whom disclosure is reasonably necessary for this Action and 3 who have signed the “Acknowledgment and Agreement to Be 4 Bound” (Exhibit A); 5 d. The Court and its personnel; 6 e. Court reporters and their staff; 7 f. Professional jury or trial consultants, mock jurors, and 8 Professional Vendors to whom disclosure is reasonably 9 necessary or this Action and who have signed the 10 “Acknowledgment and Agreement to be Bound” attached as 11 Exhibit A hereto; 12 g. 13 information or a custodian or other person who otherwise 14 possessed or knew the information; 15 h. 16 witnesses, in the Action to whom disclosure is reasonably 17 necessary provided: (i) the deposing party requests that the 18 witness sign the “Acknowledgment and Agreement to Be 19 Bound;” and (ii) they will not be permitted to keep any 20 confidential information unless they sign the 21 “Acknowledgment and Agreement to Be Bound,” unless 22 otherwise agreed by the Designating Party or ordered by the 23 Court. Pages of transcribed deposition testimony or exhibits to 24 depositions that reveal Protected Material may be separately 25 bound by the court reporter and may not be disclosed to The author or recipient of a document containing the During their depositions, witnesses, and attorneys for 26 27 28 11 STIPULATED PROTECTIVE ORDER 1 anyone except as permitted under this Stipulated Protective 2 Order; and 3 i. 4 personnel, mutually agreed upon by any of the parties engaged 5 in settlement discussions. Any mediator or settlement officer, and their supporting 6 7 IX. PROTECTED MATERIAL SUPOENAED OR ORDERED 8 PRODUCED IN OTHER LITIGATION 9 A. If a Party is served with a subpoena or a court order issued in other 10 litigation that compels disclosure of any information or items designated in 11 this Action as “CONFIDENTIAL,” that Party must: 12 1. Promptly notify in writing the Designating Party. Such 13 notification shall include a copy of the subpoena or court order; 14 2. 15 or order to issue in the other litigation that some or all of the material 16 covered by the subpoena or order is subject to this Protective Order. 17 Such notification shall include a copy of this Stipulated Protective 18 Order; and 19 3. 20 be pursued by the Designating Party whose Protected Material may 21 be affected. Promptly notify in writing the party who caused the subpoena Cooperate with respect to all reasonable procedures sought to 22 B. 23 served with the subpoena or court order shall not produce any information 24 designated in this action as “CONFIDENTIAL” before a determination by 25 the Court from which the subpoena or order issued, unless the Party has 26 obtained the Designating Party’s permission. The Designating Party shall 27 28 If the Designating Party timely seeks a protective order, the Party 12 STIPULATED PROTECTIVE ORDER 1 bear the burden and expense of seeking protection in that court of its 2 confidential material and nothing in these provisions should be construed as 3 authorizing or encouraging a Receiving Party in this Action to disobey a 4 lawful directive from another court. 5 6 X. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE 7 PRODUCED IN THIS LITIGATION 8 A. 9 Non-Party in this Action and designated as “CONFIDENTIAL.” Such The terms of this Order are applicable to information produced by a 10 information produced by Non-Parties in connection with this litigation is 11 protected by the remedies and relief provided by this Order. Nothing in 12 these provisions should be construed as prohibiting a Non-Party from 13 seeking additional protections. 14 B. 15 produce a Non-Party’s confidential information in its possession, and the 16 Party is subject to an agreement with the Non-Party not to produce the Non- 17 Party’s confidential information, then the Party shall: In the event that a Party is required, by a valid discovery request, to 18 1. Promptly notify in writing the Requesting Party and the Non- 19 Party that some or all of the information requested is subject to a 20 confidentiality agreement with a Non-Party; 21 2. 22 Protective Order in this Action, the relevant discovery request(s), and 23 a reasonably specific description of the information requested; and 24 3. 25 Non-Party, if requested. Promptly provide the Non-Party with a copy of the Stipulated Make the information requested available for inspection by the 26 27 28 13 STIPULATED PROTECTIVE ORDER 1 C. If the Non-Party fails to seek a protective order from this court 2 within 14 days of receiving the notice and accompanying information, the 3 Receiving Party may produce the Non-Party’s confidential information 4 responsive to the discovery request. If the Non-Party timely seeks a 5 protective order, the Receiving Party shall not produce any information in 6 its possession or control that is subject to the confidentiality agreement with 7 the Non-Party before a determination by the court. Absent a court order to 8 the contrary, the Non-Party shall bear the burden and expense of seeking 9 protection in this court of its Protected Material. 10 11 XI. UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL 12 A. 13 disclosed Protected Material to any person or in any circumstance not 14 authorized under this Stipulated Protective Order, the Receiving Party 15 must immediately (1) notify in writing the Designating Party of the 16 unauthorized disclosures, (2) use its best efforts to retrieve all 17 unauthorized copies of the Protected Material, (3) inform the person or 18 persons to whom unauthorized disclosures were made of all the terms of 19 this Order, and (4) request such person or persons to execute the 20 “Acknowledgment and Agreement to be Bound” that is attached hereto as 21 Exhibit A. If a Receiving Party learns that, by inadvertence or otherwise, it has 22 23 24 25 26 27 28 XII. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE PROTECTED MATERIAL A. When a Producing Party gives notice to Receiving Parties that certain inadvertently produced material is subject to a claim of privilege 14 STIPULATED PROTECTIVE ORDER 1 or other protection, the obligations of the Receiving Parties are those set 2 forth in Federal Rule of Civil Procedure 26(b)(5)(B). This provision is 3 not intended to modify whatever procedure may be established in an e- 4 discovery order that provides for production without prior privilege 5 review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as 6 the parties reach an agreement on the effect of disclosure of a 7 communication or information covered by the attorney-client privilege or 8 work product protection, the parties may incorporate their agreement in 9 the Stipulated Protective Order submitted to the Court. 10 B. To that end and, in the interest of expediting discovery in these 11 proceedings and avoiding unnecessary costs, (a) inadvertent or 12 unintentional disclosure of privileged information and/or work product 13 shall not be deemed a waiver, in whole or in part, of any otherwise valid 14 claim of privilege, immunity, or other protection; and (b) failure to assert 15 a privilege and/or work product as to one document or communication 16 shall not be deemed to constitute a waiver, in whole or in part, of the 17 privilege, immunity, or other protection as to any other document or 18 communication allegedly so protected, even involving the same subject 19 matter. In the case of inadvertently produced privileged and/or work 20 product documents, upon the recipient becoming aware that he or she has 21 received such documents that were inadvertently produced, or upon a 22 request made by the producing party, the documents together with all 23 copies made of them and any notes made from them shall be returned 24 forthwith to the party claiming privilege and/or work product immunity. 25 Any party may, within five (5) business days after notification of 26 inadvertent disclosure under this paragraph, object to the claim of 27 28 15 STIPULATED PROTECTIVE ORDER 1 inadvertence by notifying the designating or producing party in writing of 2 that objection and specifying the designated or produced material to 3 which the objection is made. The parties shall confer within fifteen (15) 4 days of service of any written objection. If the objection is not resolved, 5 the designating party shall, within fifteen (15) days of the conference, file 6 and serve a motion to resolve the dispute. If a motion is filed, information 7 subject to dispute shall be treated consistently with the designating or 8 producing party’s most recent designation until otherwise ordered by the 9 Panel. 10 11 XIII. MISCELLANEOUS 12 A. Right to Further Relief 13 1. 14 its modification by the Court in the future. 15 B. Nothing in this Order abridges the right of any person to seek Right to Assert Other Objections 16 1. 17 waives any right it otherwise would have to object to disclosing or 18 producing any information or item on any ground not addressed in 19 this Stipulated Protective Order. Similarly, no Party waives any right 20 to object on any ground to use in evidence of any of the material 21 covered by this Protective Order. 22 C. By stipulating to the entry of this Protective Order, no Party Filing Protected Material 23 1. 24 must comply with Civil Local Rule 79-5. Protected Material may 25 only be filed under seal pursuant to a court order authorizing the 26 sealing of the specific Protected Material at issue. If a Party's request 27 28 A Party that seeks to file under seal any Protected Material 16 STIPULATED PROTECTIVE ORDER 1 to file Protected Material under seal is denied by the Court, then the 2 Receiving Party may file the information in the public record unless 3 otherwise instructed by the Court. 4 5 XIV. FINAL DISPOSITION 6 A. After the final disposition of this Action, as defined in Section V, 7 within thirty (30) days of a written request by the Designating Party, each 8 Receiving Party must return all Protected Material to the Producing Party or 9 destroy such material. As used in this subdivision, “all Protected Material” 10 includes all copies, abstracts, compilations, summaries, and any other 11 format reproducing or capturing any of the Protected Material. Whether the 12 Protected Material is returned or destroyed, the Receiving Party must 13 submit a written certification to the Producing Party (and, if not the same 14 person or entity, to the Designating Party) by the 30 day deadline that (1) 15 identifies (by category, where appropriate) all the Protected Material that 16 was returned or destroyed and (2) affirms that the Receiving Party has not 17 retained any copies, abstracts, compilations, summaries or any other format 18 reproducing or capturing any of the Protected Material. Any attorney of 19 record in this action who provides access to Confidential Information to any 20 expert, consultant, witness, or other person (as defined in Paragraph III) is 21 responsible for the retrieval from any such expert, consultant, witness, or 22 other person of all documents designated as Confidential; as well as the 23 work product prepared by any such expert, consultant, witness, or other 24 person derived from that Confidential Information. Such materials shall be 25 destroyed and/or returned to that attorney of record. 26 27 28 1. Notwithstanding this provision, Counsel are entitled to retain an 17 STIPULATED PROTECTIVE ORDER 1 archival copy of all pleadings, motion papers, trial, deposition, 2 and hearing transcripts, legal memoranda, correspondence, 3 deposition and trial exhibits, expert reports, attorney work 4 product, and consultant and expert work product, even if such 5 materials contain Protected Material. Any such archival copies 6 that contain or constitute Protected Material remain subject to 7 this Protective Order as set forth in Section V. This Agreement, 8 and the obligation to keep Confidential Information confidential, 9 shall survive the final termination of this action. 10 B. Any violation of this Order may be punished by any and all appropriate 11 measures including, without limitation, contempt proceedings and/or 12 monetary sanctions. 13 14 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 15 16 Dated: April 12, 2021 17 18 19 /s/ Alexander L. Conti Alexander L. Conti CONTI LAW Attorney for Plaintiff Trelleborg Sealing Solutions US, Inc. 20 21 22 23 24 Dated: April 12, 2021 /s/ Michelle M. Fujimoto Michelle M. Fujimoto SHOOK, HARDY & BACON L.L.P. Attorney for Defendant Precision Wire Components, LLC d/b/a Creganna Medical 25 26 27 28 18 STIPULATED PROTECTIVE ORDER 1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 2 3 Dated: 4 April 13, 2021 /s/ Autumn D. Spaeth HONORABLE AUTUMN D. SPAETH United States Magistrate Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 19 STIPULATED PROTECTIVE ORDER 1 EXHIBIT A: ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 2 3 I, 4 [print or type full name], of [print or type full address], declare under penalty of perjury 5 that I have read in its entirety and understand the Stipulated Protective Order that 6 was issue by the United States District Court for the Central District of California 7 on [DATE] in the case of Trelleborg Sealing Solutions US, Inc. v. Precision Wire 8 Components, LLC d/b/a Creganna Medical, Case No. 8:20-cv-01966 JLS 9 (ADSx). I agree to comply with and to be bound by all the terms of this 10 Stipulated Protective Order and I understand and acknowledge that failure to so 11 comply could expose me to sanctions and punishment in the nature of contempt. I 12 solemnly promise that I will not disclose in any manner any information or item 13 that is subject to this Stipulated Protective Order to any person or entity except in 14 strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District 16 Court for the Central District of California for the purpose of enforcing the terms 17 of this Stipulated Protective Order, even if such enforcement proceedings occur 18 after termination of this action. I hereby appoint 19 [print or type full name] of [print or type full 20 address and telephone number] as my California agent for service of process in 21 connection with this action or any proceedings related to enforcement of this 22 Stipulated Protective Order. 23 Date: 24 City and State where sworn and signed: 25 Printed Name: 26 Signature: 27 28 20 STIPULATED PROTECTIVE ORDER

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